Trump Administration Targets Higher Ed Accreditation

Reform is Needed--After We Step Back and Determine the Point

The Wall Street Journal was the first to break the news that President Trump was set to issue an Executive Order to shake up accreditation in higher education; he did so later in the day. Back in November 2024 just after the election, the President described changing accreditation as his ‘secret weapon’ to rid higher education of liberal bias, by reducing their power and reserving some of it to the Department of Education (that he is abolishing). Or something. The November piece noted that changing arcane accreditation rules could be among the most potent means of bending higher education toward the President’s liking since direct financial action was limited:

“Although a president can’t immediately cut off money to any school, he could use various laws to pressure schools to address antisemitism on campus, disband programs that focus on nonwhite student groups or reduce accommodations for transgender students.”

While that bit of analysis from the November 11, 2024 piece did not hold up so well, it did correctly foreshadow the President’s focus on higher education as a part of his efforts to roll back “DEI” and “woke America” of which he views universities as ground zero.

I am going to try and step back and lay out some ideas for needed reforms in accreditation, while suggesting that some of the topics wrapped up in the discussion of same may not best be addressed via that route. You do not have to believe that the Trump Administration comes in good faith to know that we need to make changes in higher education, and particularly in ensuring that the education we provide is what students need and that it is worth their time, effort and money invested.

But First, A Confession

I am not sure that I spent five minutes during my first 20 years as a professor at Duke thinking about accreditation. I knew that it was a thing, and provided materials requested and the like when my department participated in accreditation review tasks, but there were more clarifying things for me to worry about, such as getting my research done so that I would get tenure instead of being fired.

Six or seven years ago, I was asked to participate in a four-person external review team for the colleges of Arts and Sciences at an old school public Big 10 University (one of the ones where it is cold in the winter). This effort was a part of a self-study that was to inform the next accreditation review of said University. However, I thought of myself as participating in a type of peer review whereby I brought my experience as a faculty member and researcher to another institution and the result was both to provide insight as well as to learn. In fact, one of the things that stands out for me about the experience was discovering this institutions success rate with NSF early-career awards in the quantitative social sciences as compared with Duke’s. Pride being one of the seven deadly sins and me being a professor at Duke, I was surprised by the divergence, and asked if the data were correct. It was and I eventually developed an insight into how the award applications were written and structured that had provided the nudge. The point is that I agreed to do this time-consuming review both because service of this type is expected of faculty as well as it afforded me with an opportunity to learn.

I was participating in accreditation but doing so in a way that made sense as an academic—peer review. However, I have come to understand how many steps, people and work there are buffering such peer review, delaying the effect of feedback.

About 16 months ago I got my first taste of accreditation up close and personal. I agreed to chair a committee that had to address a knotty question related to faculty appointments at Duke Kunshan University and their relationship to Duke faculty and Duke university departments. Accreditation figured centrally in this effort because Duke’s agreements with our partners in China to create a new institution made reference to accreditation-facing metrics in both nations. When doing the review of the college of Arts and Sciences for the Big 10 University, I was participating in academic peer review, and someone else took that output and interpreted into that institution’s accreditation requirement. When I served as the Chair of the Duke committee, I had to begin in the accreditation regulations and work back into the problem that Duke had to fix (I am not saying more about the actual accreditation issue because it was addressed in executive session of the Duke Academic Council as most of our China-facing business is handled and such deliberations are confidential). Suffice it to say that I had no idea how complicated were some of the processes and procedures involved in an accreditation review, or how many answers to seemingly straightforward questions were “it depends.”

Reform of accreditation is needed. But, first a bit of history, because it has an effect on where we go from here.

The Southern Association of Colleges and Schools Commission on Colleges (SACSCOC) is the accrediting body for Duke University, and Duke is a member of same. The members set the rules and procedures, and then the process of review determines if universities have followed their own rules in the way they said they would do so. There are hard and fast rules that relate primarily to finances at the institutional level. Questions like does the organization have necessary financial reserves to cushion shocks. However, on the academic side of things, I think accreditation is best thought of as a type of continuous improvement whereby universities state goals within broad parameters, and SACSCOC or other organization judges whether they stated plans have been followed. I am sure I am missing some hard and fast rules, but for example, there are none about online classes. Duke does not use them widely (except for during COVID) because that is not what we do. Other colleges do, and that is fine under the rules because they say they will do so.

This is not necessarily a problem, but it is important to understand that outside of finances, there are not so many hard and fast rules for academics outside of you have to be clear about what you plan to do, why, and then do it.

Accreditors do render adverse judgements, and at times that results in loss of accreditation. The screenshot below provides the most recent public statements about colleges and universities that have been found deficient in some substantial manner by SACSCOC. Note that almost all cases of accreditation deficiencies are related to finances, mismanagement of funds and not having appropriate financial reserves and not academic quality (this piece by Samuel Negus at Hillsdale College reports on some empirical analysis he did that bears this out nationally). When you hear a story about an institution struggling with accreditation, it often makes the news because they cannot meet payroll, or service a debt, or are cutting majors to deal with these problems. It is not because of whether or how they taught Cicero or Marx.

The current approach to college accreditation is geographically constituted and has been since 1952 for SACSCOC that covers the South. Within the South, SACSCOC accredits every type of institution of higher education from community colleges, to the University of North Carolina at Chapel Hill, to Duke….and the institutions noted above who have been found to be deficient recently and/or identified as having rectified problems. All of them. Note that President Trump altered the accreditation rules during his first term that allowed universities to change accrediting agencies, though most did not change. And the North Carolina General Assembly required constituent campuses to change accrediting agencies every ten years to address issues of regulatory capture and the like, so desiring competition among accreditors has been a Republican political position for some time. An institution that lost its accreditation would lose access to Title 6 funding if not rectified which would stop a college or university from receiving Pell grants, federally funded work study and their students would likely lose access to federally arranged educational loans. These would be devastating outcomes for any college or university, but likely the death knell for those in the list above. Virginia Union University’s case is illustrative;

What is the Point of Accreditation? Has it Changed Over Time?

OK, that is a bit of the context of how it works. But what are we trying to do? What is the point of accreditation?

The idea of and need for accreditation arose in the 1950s to ensure that vast federal money pouring into higher education via the GI Bill was being appropriately spent. SACSCOC was created in 1952 along with several other organizations that continue to operate today (Andrew Gillen has a good history of accreditation, with comprehensive thoughts about potential reforms framed as reform v. abolish accreditation). In the 1950s, US society had decided to invest vast sums into higher education, and was seeking to avoid explicit fraud. Three quarters of a Century later, there remain concerns about fraud but much more focus on the question of appropriateness of the education being provided to students and at what cost. The question is really what is the value of the education being provided? Relevant topics to address value include cost of attendance, graduation rates, student knowledge and career preparation, job outcomes, and student debt. The sector is obviously more mature, and a rethink of accreditation is a good idea, and the process should be informed by the fact that most actions taken by accreditors focus on financial solvency of the institution and not evaluating the outcomes relevant to teaching students.

I would like to suggest three main questions that need to be answered about higher education writ large. These questions need to be unpacked first to determine if/how accreditation is the most appropriate way of changing policy to get desired outcomes.

The three key questions that need to be answered about higher education in the United States:

• Is Federal money being well spent?

  • this includes fraud defined as illegal acts, but encompasses the broader questions below

• Are students and families getting good value for what they spend on education?

  • this requires considering an undergraduate degree as a private good; are students and families getting what they pay for?

• Is higher education as a sector ‘worth it’ to the society who invests in it?

  • this requires considering an undergraduate degree as a public good

  • there are broader questions that must be assessed to identify societal value/worth like research, knowledge and intellectual property that do not directly apply to accreditation. These questions must be answered, but accreditation is not the best way to do so.

Some of these are better addressed via accreditation than others, but these three questions and their applications need to be front of mind in discussions of the Trump Administration’s accreditation Executive Order.

Is Federal Money Being Well Spent?

Let’s imagine a world in which the federal government directly provides support to low-income students that follows them wherever they decide to attend college, and further that facilitates a market for educational loans that are taken out only if the student/family choose to finance an undergraduate degree in this way. This sounds a lot like what Republican politicians and political conservatives/libertarians often argue for in the K-12 education debate around school choice and vouchers—let the money student-made private decisions.

And that is exactly what we have had in higher education for some time. That is what we are saying needs to be reformed.

Pell Grants are based on family income and students take those dollars where they wish to college. To Duke, UNC, Guilford College or Wake Technical Community College. All students are eligible if they are U.S. citizens, including scholarship athletes. Second, federal student loans are agreed to be taken out or not by student/family decisions about where to attend.

Colleges and universities provide student financial aid packages that encompass Pell Grants (if a student is eligible), federally funded work study (if a student is eligible), University specific financial aid and scholarships, both funded by the university. And finally, student loans. A student aid ‘package’ could include all, some or none of these items, and of course families may undertake private borrowing or intergenerational wealth transfers to finance education. About half the undergraduates at Duke do not apply for financial aid, while 22% of the class of 2028 were Pell Grant eligible.

There are plenty of market-driven analyses and observations about the cost of higher education and distortions in the market for choosing a college that can be made:

• regulation drives up cost;

• price competition by universities is rare, perhaps suggesting collusion; or, perhaps reputational competition leads to escalation of cost (this is similar to health care and both inflated around twice CPI for 40-50 years);

• a college degree has long been viewed as a key factor in maintaining or climbing the social ladder in the U.S., causing some to misvalue the economic worth of their course of study, or the risk of beginning but not completing a degree. They simply assumed it was worth it financially because of how much society talks up higher education.

Market distortions abound, but for all the problems in higher education, one of them is not that students and families do not have lots of choices. They not only have choices, but the federal subsidy provided either in the form or aid or loans is triggered based on individual, market driven decisions about where to attend. Let’s not lose this reality in any reform.

I am unsure of how to best identify and address outright fraud in education, but the tort system is one way, as is an explicit consumer protection approach (more on that below). To dig in and answer the crucial questions about federal money and if it is well spent, we need to first address the other questions which I will do next before tying it all together.

Are students and families getting good value for what they spend on education?

In the market for toasters, if you get your new one home and it does not work, the seller will either provide you with another toaster or refund your money. Nothing like this exists for higher education. That is in part because the value of a degree is more complex to evaluate than is the task of toasting bread. But, higher education owes a ‘good deal’ to our students, especially given low graduation rates at some universities and the student debt crisis (Duke’s four year graduation rate is 89%, and by year six it is 96%). These are unusually high rates of graduation and there is work to do across the sector. For example, the four-year graduation rate at the University of North Carolina at Wilmington is 56%; at UNC Pembroke it is 45%. The Trump Administration tags the four year rate at 64% overall. One in three not graduating after staring is a signal of problems, only some of which could plausibly be addressed by accreditation.

An undergraduate degree should form productive citizens (of the nation and world) who are prepared for the next step in their career journey. There are different approaches to education that can achieve this goal, and we should make sure not to throw the baby out with the bathwater. However, we need to confront the reality that many students do not finish their degree and having student debt and no degree is a particularly bad outcome. For students who do graduate, there are many divergent outcomes from the great (I got my dream job!) to bad (I cannot get a job that allows me to pay back my student debt). We need a policy that can prevent colleges and universities from systematically providing a ‘bad deal’ to students and their families. And everything in between. It may be easier to identify the problem that it is to know the fix, but correctly defining reality is a key part of the equation.

Is higher education as a sector ‘worth it’ to society who invests in it?

This question requires thinking about a college degree as a public good. Will Bunch argues in his 2022 book, After the Ivy Tower Falls that higher education was funded as a public good from the end of World War II until 1990 or so, but that since it has been treated as a private good for financing purposes, while still expected to produce public goods. His argument is worth a read, but it seems clear to me that there are still public goods that should be expected given all the treasure that American society has invested in higher education (tax exempt status, etc). Perhaps it is time for a more explicit distinction between the undergraduate degree (private good) and the research/intellectual property, service and health care delivery outputs of research universities (public goods).

Accreditation focuses on degree granting and not research, though the financial metrics that are assessed in accreditation are clearly related to research, especially at an R1 institution. For the time being, let’s carve out the educational aspect of higher education from the research which will have the effect of tilting the analysis toward an undergraduate degree being assessed as a private good, thus elevating the importance of graduation, cost and student debt. I think that is appropriate from a public policy perspective, because we are directly litigating (literally) the Trump Administration’s attempt to change via fiat the financing of infrastructure costs of universities paid via NIH indirect cost recovery). In accreditation, and accreditation adjacent discussions lets focus on the undergraduate degree and making sure we are providing value for money.

What Did President Trump’s Executive Order Say?

Here is a fact sheet from the White House about the President’s EO and highlights what is important to him. The biggest themes that stand out are the desire to expand the number of accreditors, thereby increasing competition among accreditors and reigning in the liberal/woke accrediting agencies that have been around for a long time. I agree with Andrew Gillen here that if the problem is overly ideological accreditation, then the last thing we need is further politicization by providing conservative accreditors, liberal ones and so on. At the same time, allowing the Federal Department of Education to undertake this task is fraught given the past 100 days and would set up even larger policy changes in policy than we have seen in title 9 across administrations, every four years.

The EO also instructs the Attorney General and Secretary of Education to do their jobs and enforce the discrimination laws of the United States, and he name drops law schools and schools of medicine, presumably because they are not covered by the 2023 Supreme Court ruling that ended the use of race is undergraduate admissions. The goal of the Administration will likely be to engage university professional schools to end DEI/race based preferences of any type, with a goal is obtaining self-modification to avoid litigation.

The final theme that comes through the latest EO is the claim that accreditors have imposed DEI on universities and that these efforts must end. While Columbia, Harvard and others have been targeted with cancellations of grants if numerous campus changes are not made, altering accreditation standards can effect many schools with limited NIH or other federal research funding. This is likely why President Trump called accreditation his secret weapon in riding DEI and wokeness from universities right after the 2024 election.

The Trump Administration’s Accreditation EO identifies some of the problems I noted above, like low graduation rates, high cost of education, low value degrees and the like but there appears to be no substance or policy suggested to address these problems. And they are real problems that need to be addressed.

WHAT IS THE WAY FORWARD ON ACCREDITATION?

Below I try and pull all this together to suggest a public policy agenda that could be viewed as a reform of accreditation, but one that represents a big change. First, we need a big step back and ask what are the problems we are trying to prevent and address, and what are the positives we are seeking to get more of via accreditation? These are fundamental questions that go well beyond the question of reform or replace accreditation. Seventy five years after accreditation began, the time is right for a full rethink, and the Trump Administration is calling the question. Those of us on the inside need to answer.

The original idea of accreditation was to ensure that federal money was being reasonably spent as the GI Bill and the NIH Act of 1950 literally jammed money to existing colleges and universities to jumpstart the beginning of what we see today. This remains an important task, and agencies of the federal government can and do hold universities accountable. We at Duke know this to be painfully true as we settled a false claims act litigation for the largest fine ($112.5 Million) ever assessed for NIH fraud in 2019 during the first Trump Administration. This outcome reverberated across Duke-wide research practices and lead to a restructuring of numerous lines of authority. Duke and all other universities must follow the law and the federal government can and should follow and enforce it. The timescale and diffuse nature of accreditation should have no role to play in policing misspent federal money going forward.

The high minded and important ideals of accreditation—that a university has goals for research, teaching and student well-being intellectually and otherwise, and the process of self-reflection that helps identify plans and processes to reach goals is a good one. However, there is lots lost in the shuffle of accreditation and there is a great deal of administrative work that may not represent the most efficient use of resources. How accreditation could be restructured to provide more timely feedback on the important quality improvement goals of accreditation at lower cost to all involved is unclear to me, but that should be the goal.

The big idea of the Trump Administration’s EO is to increase competition among accreditors and that will improve outcomes. More competition is a tried-and-true American big idea and it works for most goods (see HOKA disrupting Nike and Addidas) so it sounds like it makes sense to casual observers or ideologues who want to use accreditation to continue ideological war against universities. However, a college degree is more complicated that a pair of running shoes so the notion that competition among accreditors will improve outcomes is highly questionable.

Sticking with the running shoes theme, I was struck by a conversation with a Duke student last year who talked of agonizing over her choice of what school to attend. She had great choices: Davidson, Duke and UNC Chapel Hill. In one sense, this is a perfectly reasonable choice set for a high achieving high school student from North Carolina, but from the perspective of the experience of being a college student these choices are super different. Two research universities in the top 15 of NIH expenditures, one with a large student body, the other with a smallish one, and an elite liberal arts teaching college that was smaller than this kids high school in terms of number of students. I told her I found those choices bizarre given how divergent the experience as a student would be at them, and she really had no idea what I was talking about. And I did not do a good job of convincing her. She wants to go to medical school and plans to major in biology and all them could get her to that goal.

The amazing choice demonstrated in this decision set is something that we need to maintain to keep the advantage of the U.S. in higher education that we have long had globally, but we need to be far more transparent about inputs and outputs than we are at present. Somehow we need to find more and better information to describe not only costs, debt and benefits, but the reality of being a student to help students make up their own minds. In this way we are supporting the market-based notion of consumer choice, but the intervention is more data and not more accreditors with different points of view.

The Trump Administration’s EO has the metrics that need to be looked at—graduation rates, cost, student debt, and some measure(s) of the financial return on a degree need to be calculated and shared. I believe quite strongly that education provides public goods that benefit us all and operate as more thoughtful citizens, but those are second-order effects at best and the fiscal situation of the United States and the World mean that we must look inward and make sure the degrees we offer do needlessly indebt our students. Society does not trust us to self-police and I don’t think I blame them, though it pains me to say it. One way that universities could put our money where our mouth is about the public good value of higher education is to offer loan repayment assistance based on the income that our students actually make. Harvard Law School has such a program, as does the Johns Hopkins School of Public health whereby students in public service/low income jobs get privately funded debt relief. Here me clearly—Duke University does not have the resources to simply do this and keep doing everything else that we do. I am saying that as we seek to use the chaos of the past 100 days on campus to focus, this is a way that we could proceed with a type of ‘salary floor guarantee’ for our undergraduate students.

I think that it makes policy sense to explicitly move toward state-enforced consumer protection for higher education to provide information about costs, graduation rates and employment outcomes. Individual states, or groups of states that make sense to them could do so together. In North Carolina, the Attorney General has a consumer protection division and they should assemble and provide data on all colleges and universities in North Carolina that focus on cost, debt, graduation, salary after school. This can be viewed as a market adjacent intervention because of its role in providing information to ensure that students and families are making informed choices.

The vast majority of actions taken by accreditors against colleges and universities focus on financial issues that put the school at risk of going bankrupt. The measures used by accreditors to judge financial health and care of same seem reasonable, but this task of assessing the financial health of an institution of higher education also seems best left to state government. The analysis is not dissimilar to how departments of insurance accredit continuing care retirement communities where fixed and marginal costs must be covered by flows and unpredictable life span. The key question for regulators there is what reserves are required to remain able to accept new patients, and once new patients cannot be accepted the organization will cease to exist. The fixed costs, marginal costs and flow dynamics of colleges and universities are similar. I would start by assigning this task to the same state agency and/or multi-state compact that provides data on graduation rates and the like.

Perhaps the only thing that would be worse than doing nothing viz accreditation would be to federalize it. The federal government can and does enforce the law with respect to expenditure of federal money and the civil rights laws, none of which have been altered in the last 100 days. The flurry of activity via Executive Orders targeted toward universities has included much content that I believe to be unconstitutional and illegal (lack of due process) overreach and it is all being litigated and eventually the courts will decide. For example, three separate rulings yesterday halted different Trump Administration DEI policies in the educational realm because they were judged as likely illegal. The central issue at the heart of most the Trump Administration’s EO and other policy efforts stem from their claim that the Supreme Court ruling in 2023 that race could be used in undergraduate admissions is unconstitutional, and that is a stretch at best. Until there is more clarity from the courts, the DEI landscape will remain in flux. However, we do not need to wait for clarity there to get started developing something better than our current accreditation approach.

I am interested in feedback.

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Three documents I recommend on accreditation that are also linked at points above.

Samuel Negus of Hillsdale College The Phony War on Accreditors.

Adam Kissel the Cardinal Institute End the unjust stratification of accreditors.

Andrew Gillen Should college accreditation be reformed or abolished?